Shigenori Kudo and Motomi Kudo, et al. - Page 15

                                       - 15 -                                         
          sources in separate envelopes, but she did not save the envelopes           
          nor keep any other contemporaneous records of the sources of the            
          cash.                                                                       
               Nakamura, a certified public accountant, prepared the Kudos'           
          individual Federal income tax returns for 1990, 1991, and                   
          previous years.9   Motomi would give him a manila envelope                  
          containing the Kudos' Forms 1099, a sheet of paper listing                  
          charitable contributions and other deductions, and other items              
          she thought important.  Nakamura did not request or receive bank            
          records.  In preparing their income tax returns, Nakamura did not           
          include in the Kudos' income certain payments from Toraya,                  
          because he viewed them as nontaxable reimbursements.                        
               The Kudos owned a personal residence in San Bruno,                     
          California, during 1988 and until March 1989, when they sold that           
          residence.  During April 1989, the Kudos purchased a personal               
          residence in Burlingame, California, for which they paid                    
          $550,000.  During 1990 and 1991, the Kudos made mortgage payments           
          on their personal residence in the amounts of $31,827.72 and                
          $27,413.86, respectively.                                                   
          Facts Relating to the Takaos                                                
               When they filed their petitions, the Takaos resided in                 
          Burlingame, California.  Akiko died on June 10, 1995, at the age            
          of 69.                                                                      


               9  Nakamura also prepared the returns for the Takaos and               
          Toraya.                                                                     



Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  Next

Last modified: May 25, 2011